A Landmark Win for First Responders: Pennsylvania Court Recognizes PTSD as a Valid Work-Related Injury for Firefighters

By Michael Dryden, Esq.

On October 23, 2025, the Pennsylvania Commonwealth Court issued a landmark decision that will forever change the way the commonwealth treats mental health injuries among first responders.

In Ganley v. Upper Darby Township, the court recognized the profound psychological toll that traumatic experiences can take on firefighters. In doing so, the court finally acknowledged that Post-Traumatic Stress Disorder (PTSD) can be a compensable workplace injury, even in the absence of physical harm.

Brought on behalf of Upper Darby firefighter Brian Ganley, this case is not just a victory for one man; it is a long-overdue acknowledgment of the invisible wounds carried by those who dedicate their lives to saving others. And while this particular decision applies only to public employees, we hope and will continue to advocate for the same fair treatment to be extended to all workers, including in the private sector.

The Story of Firefighter Brian Ganley

Firefighter Brian Ganley devoted more than 20 years of service to Upper Darby Township, earning a reputation as one of its most dedicated and decorated first responders. Over the course of his career, he responded to countless emergencies, from fires to car crashes and heroic rescues. But two tragic calls, several months apart, changed his life forever.

In both incidents – one in November 2018 and one in May 2021 – Ganley responded to the scenes of infant medical emergencies. Despite his best efforts, including performing CPR, both infants died. These devastating experiences affected him deeply. He was later diagnosed with Post-Traumatic Stress Disorder by physicians selected by the fire department itself. Those same doctors determined that Ganley was permanently disabled and unable to return to work as a firefighter.

Despite these findings, Upper Darby Township denied him workers’ compensation benefits. The township claimed that the emotional trauma Ganley suffered, though devastating, did not result from “abnormal working conditions,” a long-standing legal standard in Pennsylvania that has historically made it nearly impossible for first responders to recover benefits for psychological injuries alone.

The Long Road Through the Legal System

Ganley’s claim first was denied by a Workers’ Compensation Judge, who relied on precedent to determine that witnessing infant deaths, while tragic, was not “abnormal” for a firefighter. The decision was upheld by the Pennsylvania Workers’ Compensation Appeal Board, continuing a pattern in Pennsylvania law that denied benefits for mental health injuries if they were not accompanied by physical trauma.

But Ganley refused to give up, and neither did we. Together with my legal team, I appealed the decision to the Pennsylvania Commonwealth Court, where, for the first time, the judiciary took a deep and compassionate look at what “abnormal working conditions” really means in the modern era.

A Landmark Decision: Recognizing the Invisible Injuries

In a thorough and thoughtful majority opinion, the Commonwealth Court reversed the lower court’s decision, finding that the horrific circumstances Ganley experienced — the deaths of two infants he personally tried to save — were indeed abnormal working conditions for a firefighter.

This recognition marked a seismic shift in Pennsylvania workers’ compensation law. For the first time in the Commonwealth’s history, a firefighter was awarded benefits for PTSD without any accompanying physical injury.

The Court’s reasoning acknowledged what mental health professionals, first responders, and advocates have long known: that psychological trauma is real, debilitating, and deserves to be treated with the same seriousness as physical injuries.

The Concurring Opinion: A Call to Modernize the Law

Equally significant was the concurring opinion in the case, which went even further. The concurring judge urged that the “abnormal working condition” standard itself should be scrapped altogether. The opinion noted that this outdated legal concept forces courts to make “elusive distinctions” about what is normal or abnormal in high-risk professions, distinctions that often ignore the reality of modern psychological understanding.

The concurring opinion emphasized that the abnormal working condition rule emerged in an era when mental health was poorly understood and undervalued. By holding on to that outdated framework, courts have unintentionally invalidated the very real suffering of public servants such as firefighters, paramedics, police officers, and emergency dispatchers.

The Ganley decision signals that Pennsylvania courts are ready to move beyond this antiquated view toward one that respects, validates, and compensates mental and emotional injuries just as they would a broken bone or a burn.

Why This Case Matters for First Responders Across Pennsylvania

The implications of Ganley v. Upper Darby Township extend far beyond one firefighter. For decades, Pennsylvania’s “abnormal working condition” standard effectively barred first responders from receiving compensation for PTSD unless the trauma was tied to a physical injury.

That changes now.

Future firefighters, police officers, and EMS professionals who experience trauma on the job, whether from a fatal accident, a mass casualty event, or repeated exposure to human suffering, will be able to rely on Ganley as precedent. The decision opens the door to a more compassionate and scientifically informed approach to mental health care in public service.

As society’s understanding of mental wellness evolves, so too must the law. The Ganley case represents a long-overdue step toward aligning Pennsylvania’s legal framework with modern medical and psychological standards.

A Path Forward: Recognizing the Human Cost of Heroism

Firefighter Brian Ganley’s courage did not end when he hung up his gear. By standing up and challenging an unjust system, he has paved the way for others who suffer in silence. His case has forced Pennsylvania to confront a painful truth: that the emotional scars borne by first responders are every bit as real as their physical ones.

The Ganley decision is a legal victory and also a moral victory, setting a precedent for the protection and dignity of those who risk everything for their communities. It carves a new path forward for Pennsylvania, sets a powerful example for the nation, and stands as a testament to resilience, justice, and the long-overdue respect for the invisible injuries carried by our everyday heroes.